Hi, since the GSEs are requiring compliance with the new General QM Final Rule (Freddie Mac Bulletin 2021-13) as of July 1, 2021 (rather than the CFPB's proposed October 2022 date), I'm digging into this Final Rule again.
Under the new Final Rule, a loan is General QM if the APR doesn't exceed the APOR by more than 2.25% as of the date the interest rate is set. Furthermore, the loan still qualifies as a Safe Harbor General QM if the APR doesn't exceed the APOR by more than 1.5% as of the date the interest rate is set.
Since this is the same analysis we currently do to determine HPML classification (a loan is HPML if the APR doesn't exceed the APOR by more than 1.5% for first-lien loans as of the date the interest rate is set), is it fair to say that any non-HPML loans would qualify under the new General QM definition assuming we also meet the "consider and verify" requirements?
Along these same lines, any loans in which the APR exceeds the APOR by more than 1.5% but less than 2.25% would be considered a HPML General QM?
I really hope the new General QM Final Rule is this simplistic to implement. Thanks for your feedback.